Sec. 13013. Allocation of dividend expense among members of worldwide affiliated groups
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(6)of section 864(e) is amended to read as follows: Except as provided in subparagraph (B), expenses other than interest which are not directly allocable or apportioned to any specific income producing activity shall be allocated and apportioned as if all members of the affiliated group were a single corporation. The dividend expense of any domestic corporation which is a member of an affiliated group shall be allocated and apportioned to income from sources without the United States in the same proportion which— the aggregate amount of income treated as from sources without the United States by all domestic corporations which are members of such group (determined without regard to such dividend expense), bears to the aggregate income of all such domestic corporations from sources within and without the United States (as so determined). . The amendment made by this section shall apply to taxable years beginning after December 31, 2018.